Regulatory authorities release a new version of the negative list for personal insurance, stopping the approval of low-coverage medical insurance, dividend insurance with empty promises, and other practices.

21st Century Business Herald reporter Lin Hanyao

In the deep waters of the personal accident and health insurance industry speeding up its transition to high-quality development, the regulatory red lines for product compliance and risk prevention are tightened again.

According to a reporter from 21st Century Business Herald who learned from within the industry, the National Financial Regulatory Administration has recently formally issued the “Negative List for Personal Insurance Products (2026 Edition)” (hereinafter referred to as the “Negative List (2026 Edition)”) to all personal insurance companies. Compared with the previously issued “Negative List for Personal Insurance Products (2025)” (hereinafter referred to as the “Negative List (2025 Edition)”), which had 103 items, the “Negative List (2026 Edition)” has been expanded slightly to 105 items.

Data show that in 2025, the industry’s original insurance premium income for original insurance exceeded the 6-trillion-yuan mark for the first time in history, reaching 6.12 trillion yuan, up 7.43% year over year. Of this, original premium income for life insurance reached 4.65 trillion yuan, up 9.05%, becoming the core engine of industry growth. Against the backdrop of continued expansion in industry scale, phenomena such as product homogenization, deviation in liability design, and sales misguidance still show signs of resurfacing. In the view of industry insiders, the issuance of the “Negative List (2026 Edition)” signals that regulators are guiding the industry back to the original purpose of providing protection with higher standards and stricter requirements.

New provisions strengthen standardization in the medical and dividend areas

The reporter’s review found that the “Negative List (2026 Edition)” continues the prior framework structure, divided into four core sections: product clause expression, product liability design, product rate setting and actuarial assumptions, and product filing and submission management. Compared with the “Negative List (2025 Edition),” the 2026 edition makes targeted “patches” in multiple details and upgrades to stricter supervision.

First, in the section on “product clause expression,” the 2026 edition adds Article 27, which states: “In medical insurance product clauses, agreements on prescription review are unreasonable. It is agreed that the prescription review subject is a third-party service provider, rather than an insurance institution, and it does not clearly specify the review responsibility that the insurance company should bear.”

Industry insiders analyze that as commercial health insurance coverage of special therapies and innovative drugs continues to expand, prescription review has become a key link in claim risk control. Some insurers outsource the entire prescription review authority to third-party service providers (TPAs) in order to shift operational costs. Once a claims dispute arises, insurers and TPAs often blame each other. This regulatory move clearly requires insurance companies to assume the primary responsibility for review, and to effectively protect consumers’ lawful rights and interests in the process of using drugs for claims.

Second, against the backdrop of continued decline in interest rates and the lowering of the assumed interest rate for traditional insurance products, dividend-linked insurance has been favored by both insurers and consumers due to its “guaranteed returns + floating dividends” model. In 2025, life insurers generally stepped up efforts on dividend-linked insurance, and the business share increased significantly. However, sales misguidance issues have also risen.

To prevent future risks of sales misguidance, the “Negative List (2026 Edition)” adds, in the third part titled “Negative List (2026 Edition),” a red line in Article 86: “The dividend distribution ratio promised in the product prospectus for the dividend distribution policy of a participating insurance product, which exceeds the distribution ratio level demonstrated by the benefits illustration.” This means regulators will absolutely not allow insurers to make exaggerated promises about dividend distribution in the product prospectus. It requires that the written dividend distribution policy must maintain rigorous consistency with the actual benefits illustration using actuarial assumptions, thereby curbing noncompliant marketing from the source.

Actuarial assumptions aligned with the new life tables

In addition to the two added items, the “Negative List (2026 Edition)” further refines the granularity.

For example, in the dimension of “product liability design,” the “Negative List (2026 Edition)” builds on the existing foundation of the “Negative List (2025 Edition),” where it originally stated: “Weakening of the safeguard functions of insurance products; nursing insurance products only include nursing liabilities caused by accidental events; annuity insurance products have neither safeguard functions nor savings functions.” On this basis, it substantially expands restrictions on medical insurance, adding: “Medical insurance products with excessively high deductibles or excessively low payout ratios; and medical allowance products of the fixed benefit type with an insurance amount set too low.” This further compresses the distorted space of “low protection but high costs” in medical insurance.

In response to recent chaos in which some companies seek regulatory arbitrage through concept substitution, the “Negative List (2026 Edition)” pushes the defensive line forward further. The “Negative List (2025 Edition)” had clearly called for stopping the “incremental form design” of annuity insurance and endowment insurance when modeled after additional whole life insurance.

However, as additional whole life insurance is subject to strict control, some insurers have tried to “sneak it through” in the form of nursing insurance. In response, Article (49) of the “Negative List (2026 Edition)” adds a prohibition on “the design of an incremental form for nursing insurance with a non-whole-life coverage period that is modeled after the incremental form design of additional whole life insurance,” closing the “incremental-like” wealth-management loophole in nursing insurance.

If product clauses and liability design are the “face” of personal insurance products, then rate setting and actuarial assumptions are the “core” that determines the product’s steady operation. In this key area, the “Negative List (2026 Edition)” reflects a major iteration of the industry’s underlying actuarial infrastructure.

The biggest change is reflected in the standardized application of the industry experience life table. Article 73 of the “Negative List (2025 Edition)” focuses on whether the life table used to evaluate statutory reserve for insurance products’ liabilities and the requirements in the “Notice of the China Insurance Regulatory Commission on Matters Concerning the Use of the ‘China Life Insurance Industry Experience Life Table (2010–2013)’” are consistent.

By contrast, in the “Negative List (2026 Edition),” Article 74 comprehensively updates this underlying standard, requiring strict alignment with the “Notice of the National Financial Regulatory Administration on Matters Concerning the Release and Implementation of the ‘China Life Insurance Industry Experience Life Table (2025)’.”

The “China Life Insurance Industry Experience Life Table (2025)” (i.e., the so-called fourth life table commonly referred to within the industry) has been implemented in full since January 1, 2026. Compared with the previous version, the new life table reflects that the life expectancy of residents in China has grown by about 10 years, and the child mortality rate has improved significantly.

Against this broader backdrop, the 2026 edition negative list further proposes strict requirements: “To not prudently judge the main liabilities of the product as required and to not choose the applicable category of incidence rate tables. For medical expense compensation medical liabilities included in health insurance, the evaluation assumptions related to medical expenses must consider medical expense inflation factors as required.”

Industry insiders analyze that as average life expectancy generally increases, retirement products such as annuity insurance that cover longevity risk face greater pressure from long-tail benefit payouts. At the same time, long-term medical expense inflation is an indisputable objective fact. By mandating that regulators consider medical expense inflation factors in the actuarial assumptions for health insurance, they aim to prevent medical insurance products from facing massive claim-payment gaps in the future, and to force insurers to enhance cross-cycle fine pricing and risk management capabilities.

“Filing to comply, to execute in line” further deepened

The “Negative List (2026 Edition)” further strengthens expense control and channel compliance requirements by further refining the implementation of “filing to comply, to execute in line.”

Specifically, the “Negative List (2025 Edition)” prohibited selling channels from simultaneously submitting multiple of the following—“individual agency, internet agency, bank and postal agency, and brokerage agency”—which does not meet the relevant requirements for “filing to comply, to execute in line.” Based on this, the “Negative List (2026 Edition)” focuses the applicable subjects more precisely and revises it to: “Long-term insurance sales channels that simultaneously submit multiple of the following—‘individual agency, internet agency, bank and postal agency, and brokerage agency’—do not meet the relevant requirements for ‘filing to comply, to execute in line.’”

What is meant by “filing to comply, to execute in line” is that insurers should strictly carry out the insurance clauses and insurance rates filed for approval, ensuring that the filing content is completely consistent with actual operating conduct, and to eliminate the chaos of “one thing is filed and another is executed.”

“Filing to comply, to execute in line” was implemented first in bancassurance channels, and was then quickly rolled out across all channels, including individual agency and brokerage agency. Securities firm research points out that “filing to comply, to execute in line” is expected to drive improvements in the industry’s expense ratio, reduce overall operating costs, and enhance insurers’ ability to precisely price risks.

Regarding filing materials, the “Negative List (2026 Edition)” continues to emphasize the authenticity and consistency of expense assumptions. Behaviors such as: “insurance product filing expense assumptions inconsistent with actual expenses; unclear expense descriptions; unreasonable setting of expense levels; profit testing expenses, sales expenses, and total available expenses higher than pricing expenses; and lack of inherent logical consistency among various expenses” are all listed as prohibited acts.